Monday, March 25, 2013

Vincent v. Lake Erie Transportation Co. case brief

Vincent v. Lake Erie Transportation Co. case brief
124 N.W. 221 (Minn. 1910)

SYNOPSIS:
Appeal from judgment of the District Court for St. Louis (Minnesota), which denied defendant ship owner's motion for a directed verdict and entered a jury verdict in favor of plaintiff dock owners, in plaintiffs' action to recover for damage to their wharf allegedly caused by defendant's negligence.

OVERVIEW: Plaintiffs owned a wharf in which ships docked to unload cargo. Defendant owned a ship that docked at plaintiffs' wharf during a storm. During the storm, plaintiffs' wharf was damaged by defendant's ship. Plaintiffs brought an action against defendant to recover for the damages to their wharf. The trial court denied defendant's motion for a directed verdict and entered judgment in favor of plaintiffs, and denied defendant's motion for a new trial.

HOLDING:
On appeal, the state supreme court affirmed, reasoning the damage to plaintiffs' wharf was not caused by an act of God, which would have excused defendant's liability, but was an injury caused by the defendant's prudent intention to use plaintiffs' property for the purpose of preserving its own more valuable property, and the plaintiffs, therefore, were entitled to compensation for the injury done.

RULES:
Where the situation is one in which the ordinary rules regulating property rights are suspended by forces beyond human control, and if, without the direct intervention of some act by the one sought to be held liable, the property of another is injured, such injury must be attributed to the act of God, and not to the wrongful act of the person sought to be charged.

OUTCOME: Judgment of district court affirmed, because where injury was inflicted because defendant prudently and advisedly availed itself of the plaintiff's property for the purpose of preserving its own more valuable property, the plaintiffs were entitled to compensation for the injury done.

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